Privacy Policy

It would be helpful to start by explaining some key terms used in this policy:

We may collect and use the following personal information about you:

1. Your name and contact information, including your address, your email address and telephone number, and company details;
2. Information to enable us to check and verify your identity, e.g. your date of birth;
3. Your opinions and medical details;
4. Your gender information;
5. Your location data;
6. Your billing information, transaction and payment card information;
7. Your contact history, purchase history and saved items;
8. Information to enable us to undertake credit or other financial checks on you;
9. Information about how you use our Website, IT, communication and other systems; and
10. Your responses to surveys, competitions and promotions.

Before you use certain areas of this Website, we will ask you to register on it by requiring you to enter your personal information, including 'sensitive personal data' as defined by the Regulation. For example, we will obtain your personal data when you register to use this Website, complete the online questionnaire, send us feedback, post material, contact us for any reason, sign up to a service, and purchase goods or services.

We may also obtain sensitive personal data about you if you provide it by completing the online medical questionnaire. If you volunteer such information, you will be consenting to our processing it for the purpose of obtaining a medical opinion and purchasing the treatment. This personal data is required to provide products and services to you. If you do not provide the personal information we ask for, it may prevent us from providing products and services to you.

We may monitor your use of this Website through the use of cookies and similar tracking devices. For example, we may monitor how many times you visit, which pages you go to, traffic data, location data and the originating domain name of a user's internet service provider. This information helps us to build a profile of our users. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually. For further information on our use of cookies, please see our Cookie Policy. Occasionally we may receive information about you from other sources (such as credit reference agencies), which we will add to the information we already hold about you in order to help us personalise our service to you.

We collect most of this personal information directly from you via our Website and app, or by telephone, text or email, or video consultation. We may also collect information directly from a third party, e.g. sanctions screening providers, credit reference agencies and customer due diligence providers; and from a third party with your consent, e.g. your local GP or private Doctor, from cookies on our Website, and via our IT systems, e.g. automated monitoring of our Websites and other technical systems, such as our computer networks and connections, communications systems, email and instant messaging systems.

Under data protection law, we can only use your personal information if we have a proper reason for doing so. Our reasons include but are not limited to:

1. To comply with our legal and regulatory obligations;
2. For the performance of our contract with you or to take steps at your request before entering into a contract;
3. For the purposes of medical diagnosis and the provision of healthcare and treatment;
4. For our legitimate interests or those of a third party; and
5. Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

We may use your personal information to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in processing your personal information for promotional purposes (see above 'How and why we use your personal information'). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never share it with other organisations for marketing or other purposes. If you have given permission for us to process your personal data, we may share your personal data with associated companies and organisations that are our business partners and we or they may contact you (unless you have asked us or them not to do so) by mail, email, telephone, SMS, text/picture/video message, fax, aboutour services, products, promotions, offers, charitable causes that may be of interest to you.

You have the right to opt out of receiving promotional communications at any time by:

1. Contacting us
2. Using the 'unsubscribe' link in emails or 'STOP' number in texts
3. Updating your marketing preferences on your secure members area

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and services in the future, or if there are changes in the law, regulation, or the structure of our business.

We routinely share personal information with:

1. Associated companies and business partners;
2. Third parties we use to help deliver our products and services to you, e.g. payment service providers, warehouses and delivery companies;
3. Other third parties we use to help us run our business, e.g. marketing agencies or Website hosts;
4. Third parties approved by you, e.g. social media sites you choose to link your account to or third party payment providers;
5. Law enforcement agencies in connection with any investigation to help prevent unlawful activity;
6. Credit reference agencies;
7. Our insurers and brokers;
8. Our bank(s); and
9. Our regulators.

We share your personal information with third parties who help us to deliver targeted marketing campaigns and to personalise your experience online. These providers include Ve Global UK Limited. Click here to see Ve's privacy policy (https://www.ve.com/legal/privacy-policy) to see how your personal data is being processed. To opt out click here (https://www.ve.com/legal/privacy-policy#opting-out). You can opt out by:

• Contacting Ve at [email protected] to inform Ve that you would like to opt-out of their use of your personal information.
• Deleting cookies from your devices and browsers.
• If you are using Safari browser version 11.2 or above, toggling the "Limit Ad Tracking" setting on your device or computer.
• Visiting http://www.youronlinechoices.com/uk/your-ad-choices, finding VE in the list of online behavioural advertising companies and selecting 'off'.
• If you have an Apple device, updating to iOS 6.0 or higher and setting Limit Ad Tracking to 'ON'.
• If you have an Android device, selecting "Google on your main settings menu, choosing the "Ads" option and selecting "Opt out of Ads Personalization".

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g. in relation to ISO or Investors in People accreditation and the audit of our accounts.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

Information may be held at our offices and those of our associated companies,third party agencies, service providers, representatives and agents as described above,see above: 'Who we share your personal information with'.

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: 'Transferring your personal information out of the EEA'.

We will keep your personal data while you have an account with us or we are providing products and services to you. Thereafter, we will keep your personal information for as long as is necessary:

1. To respond to any questions, complaints or claims made by you or on your behalf;
2. To show that we treated you fairly;
3. To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. When it is no longer necessary to retain your personal information, we will delete or anonymise it.

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We continually test our systems.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

We will use technical and organisational measures to safeguard your personal data, for example:

1. Your data is stored on secure servers.
2. Payment details are encrypted using SSL technology.
3. Access to your account is controlled by a password and username that are unique to you.

While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

We may monitor and record communications with you such as telephone conversations and emails for the purpose of training, quality assurance, fraud prevention and compliance.

To enable us and other companies in our group or partner companiesto make credit decisions about you and for fraud prevention and money laundering purposes, we may search the files of credit reference and fraud prevention agencies (who will record the search). We may disclose information about how you conduct your account to such agencies and your information may be linked to records relating to other people living at the same address with whom you are financially linked. Other credit grantors may use this information to make credit decisions about you and the people with whom you are financially associated, as well as for fraud prevention, debtor tracing and money laundering purposes. If you provide false or inaccurate information and we suspect fraud, we will record this.

If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:

1. Receive on his/her behalf any data protection notices.
2. Give consent to the transfer of his/her personal data abroad.
3. Give consent on his/her behalf to the processing of his/her personal data.
4. Give consent to the processing of his/her sensitive personal data such as health information.

We may transfer your personal data to countries located outside the European Economic Area,for the purpose of fulfilling our obligations and providing our service. We may share your personal data outside the European Economic Area (EEA), e.g.:

1. With our business partners outside the EEA;
2. With your and our service providers located outside the EEA;
3. If you are based outside the EEA; and
4. Where there is an international dimension to the services we are providing to you.

When you registered with this Website, you agreed that we may transfer your personal data to countries outside the European Economic Area. Rest assured that we will always ensure any transfer is subject to appropriate security measures to safeguard your personal data. These transfers are subject to special rules under European and UK data protection law.

We may transfer your personal data to countries assessed by the European Commission as providing an adequate level of protection for personal information. We may equally transfer your personal data to non-EEA countries, which do not have the same data protection laws as the United Kingdom and EEA and in those circumstances, we will, ensure the transfer complies with data protection law and we will use standard data protection contract clauses that have been approved by the European Commission, thus safeguarding your privacy rights and giving you remedies in the unlikely event of a security breach.

If you would like further information please contact us or our Data Protection Officer (see 'How to contact us' below).

You have the following rights:

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner's Office (ICO) on individuals' rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

1. Email, call or write to us or our Data Protection Officer—see below: 'How to contact us'; and
2. Provide us with enough information to identify you, e.g. your full name, address, username, registration details and customer or account or order reference number;
3. Provide us with proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill);
4. Specify the information that is incorrect and what it should be replaced with (if you are adding us to correct any inaccuracies in your data);
5. Specify the channel you are objecting to (if you are asking us to stop processing your personal data for direct marketing purposes and your objection is not to direct marketing in general, but to direct marketing by a particular channel e.g. email or telephone);
6. Confirm right you want to exercise and the information to which your request relates.

This Privacy Policy was published on 25 May 2018 and last updated on 25 May 2018.
We may change this Privacy Policy from time to time. You should check this Privacy Policy occasionally to ensure you are aware of the most recent version that will apply each time you access this Website.

We welcome your feedback and questions. Please contact us or our Data Protection Officer by post, email or telephone if you have any questions about this Privacy Policy or the information we hold about you.

Our contact details are shown below:

 Our Data Protection Officer contact details are shown below:

We hope that we or our Data Protection Officer can resolve any query or concern you may raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.

If you would like this notice in another format (for example audio, large print, braille) please contact us (see 'How to contact us' above).